1

ICRAS Tracking and OMB Number: (1472) 1845

- 0108 v2 Revised: 11 / 07 /2013 RIN Number: XXXX

- XXXX (if applicable)
**SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT SUBMISSION** 
**A. Justification** 1. Explain the circumstances that make the collection of information necessary . Identify any legal or administrative requirements that necessitate the co llection. Attach a hard cop y of the appropriate section of each statute and regulation mandating or authorizing the collection of information , or you may provide a valid URL link or paste the applicable section 1 . Specify the review t ype of the collection (new, revision, extension, reinstatement with change, reinstatement without change) . If revised, briefl y specify the changes. If a rulemaking is involved, make note of the sections or changed sections, if applicable. This request is for an extension of t he current approval of the policies and procedures for determining satisfactory

academic progress (SAP) as required in Section 484 of the Higher Education Act of 1965, as amended (HEA). A link to the Satisfactory Academic Progress regulations is provided at 34 CFR 668.34

. These regulations identify the policies and procedures to ensure that students are ma king satisfactory

academic progress in their program at a pace and a level to receive or continue to receive Title IV, HEA program funds. If there is lapse in progress, the policy must identify

how the student will be notified and what steps are available to a student not making satisfactory

academic progress toward the completion of their program, and under what conditions a student who is not making satisfactory academic progress may continue to receive Title IV, HEA program funds. 2. I ndicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection. Institutions are required to confirm satisfactory academic progress b y a student in order to make initial or continuing disbursements of federal student financial aid. The institutions collect documentation to confirm the information provided on the Free Application for Federal Student Aid based on the requirements the Department issues in an annual Federal Register. The information is held in the institutions files and is made available to the Department during program reviews. Section 668.34(a)

– Sati sfactory academic progress policy

. This section of the regulations requires an institution to establish a reasonable satisfactory

academic progress policy to determine a student’s eligibility for Title I V, HEA program funds. The policy must identify requirements specify ing

–

1 Please limit pasted text to no longer than 3 paragraphs.2

ICRAS Tracking and OMB Number: (1472) 1845

- 0108 v2 Revised: 11 / 07 /2013 RIN Number: XXXX

- XXXX (if applicable)

 it is at least as strict as it is for students who do not receive Title IV, HEA program funds  it has a consistent application of standards to all students  the timeframe for the review of when a student’s academic progress is eval uated  the pace that a student must progress to ensure completion of their academic program within the maximum timeframe  how transferred credits affect the pace and maximum timeframe for program completion  how “financial aid warning” and “financial aid pro bation” statuses are used in progress calculations  a description of the appeal process and how it can be used to reestablish Title I V aid eligibility and i f a school doesn’t have an appeal process how a student may regain eligibility

for assistance  a notif

ication of the results of a student’s evaluation that impact their eligibility for Title IV, HEA funds. Section 668.34(c)

– Institutions that evaluate satisfactory academic progress at the end of each pay ment period. This section of the regulations identi fies the process that is followed for institutions that evaluate a student’s SAP at the end of a pay ment period. This section specif ies that an institution’s policy may provide for disbursement of Title IV aid to a student not meeting SAP under certain ci rcumstances. This include s policies that automatically

place a student who is not meeting SAP on “financial aid warning”

. Section 668.34(d)

– Institutions that evaluate satisfactory academic progress annually or less frequentl y than at the end of each pa ym ent period. This section of the regulations identifies the process that is followed for institutions that evaluate a student’s SAP on an annual basis. This section specif ies that an institution’s policy

may provide for disbursement of Title I V aid to a student not meeting SAP under certain circumstances. This include s policies that require a student to file an appeal and either having a determination made by the school that the student should meet SAP standards after the subsequent pay ment period or if the school develops, with the student, an academic plan which if successfull y completed will ensure the student meets the institution’s SAP standards at a specific time. Section 600.55(g)(1) & (2)

– Other Criteria. This regulation requires foreign graduat e medical schools to apply existing regulations in SAP for establishing maximum timeframes in which a student must complete their educational program and requires that a student complete their educational program in 150 percent of the published length of t he program. The regulations require foreign graduate medical schools to document the educational remediation it provides to assist students in making SAP. 3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or forms of information technology , e.g. permitting electronic submission of responses, and the basis for the3

ICRAS Tracking and OMB Number: (1472) 1845

- 0108 v2 Revised: 11 / 07 /2013 RIN Number: XXXX

- XXXX (if applicable) decision of adopting this means of collection. Also describe an y consideration given to using technology

to reduce burden. The institution may

provide their policy

and procedure information to students via an Internet or Intranet Web site as an efficient method to provide the SAP requirements. 4. Describe efforts to identify duplication. Show specificall y wh y an y similar information alread y available cannot be used or modified for use for the purposes described in I tem 2 above. There is no duplication of data as a result of the collection of this information. 5. If the collection of information impacts small businesses or other small entities, describe an y methods used to minimize burden. A small entit y may be (1) a small business which is deemed to be one that is independently owned and operated and that is not d ominant in its field of operation; (2) a small organization that is any not
- for

- profit enterprise that is independently owned and operated and is not dominant in its field; or (3) a small government jurisdiction, which is a government of a city , count y, to wn, township, school district, or special district with a population of less than 50,000. No small businesses are impacted b y this collection. 6. Describe the consequences to Federal program or policy activities if the collection is not conducted or is conducted less frequentl y, as well as an y technical or legal obstacles to reducing burden. The statute requires that the student’s academic progress be evaluated at least at the end of each academic ye ar or the equivalent. Evaluation at an y longer interval could risk funds being disbursed to ineligible students. 7. Explain any

special circumstances that would cause an information collection to be conducted in a manner:
 requiring respondents to report information to the agency more often than quarte rl y;  requiring respondents to prepare a written response to a collection of information in fewer than 30 day s after receipt of it;
 requiring respondents to submit more than an original and two copies of any document;
 requiring respondents to retain records , other than health, medical, government contract, grant
- in

- aid, or tax records for more than three y ears;  in connection with a statistical survey , that is not designed to produce valid and reliable results than can be generalized to the universe of study ;  requiring the use of a statistical data classification that has not been reviewed and approved b y OMB;
 that includes a pledge of confidentiality that is not supported by

authority established in statute or regulation, that is not supported by disclosure a nd data security policies that are consistent with the pledge, or that unnecessaril y i mpedes sharing of data with other agencies for compatible confidential use; or4

ICRAS Tracking and OMB Number: (1472) 1845

- 0108 v2 Revised: 11 / 07 /2013 RIN Number: XXXX

- XXXX (if applicable)

 requiring respondents to submit proprietary trade secrets, or other confidential informatio n unless the agency can demonstrate that it has instituted procedures to protect the information’s confidentiality to the extent permitted by law. The information collection requirements require no special circumstances. 8. As applicable, state that the Dep artment has published the 60 and 30 Federal Register notices as required b y 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions t aken b y the agency in response to these comments. Specifically address comments received on cost and hour burden. Describe efforts to consult with persons outside the agency to obtain their views on the availability

of data, frequency

of collection, the clarity

of instruction and record keeping, disclosure, or reporting format (if an y), and on the data elements to be recorded, disclosed, or reported. Consultation with representatives of those from whom information is to be obtained or those who must comp ile records should occur at least once every 3 y ears
– even if the collection of information activity

is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explai ned. No public comments were received during the 60 day Federal Register notice. There will be a 30

- day

Federal Register notice pu blished seeking public comment. This is the 60

- day notice

. 9. Explain any

decision to provide any

pay ment or gift to respo ndents, other than remuneration of contractors or grantees with meaningful justification

. No pay ments or gifts will be provided to the respondents. 10. Describe an y assurance of confidentiality provided to respondents and the basis for the assurance in s tatute, regulation, or agency policy . If personally

identifiable information (PII) is being collected, a Privacy Act statement should be included on the instrument. Please provide a citation for the Sy stems of Record Notice and the date a Privacy I mpact As sessment was completed as indicated on the I C Data Form . A confidentiality statement with a legal citation that authorizes the pledge of confidentiality should be provided. 2 If the collection is subject to the Privacy Act, the Privacy

Act statement is deem ed sufficient with respect to confidentiality . I f there is no expectation of confidentiality , simply state that the Department make s no pledge about the confidentiall y of the data.

2 Requests for this information are in accordance with the follow ing ED and OMB policies: Privacy Act of 1974, OMB Circular A

- 108

– Privacy Act Implementation

– Guidelines and Responsibilities, OMB Circular A

- 130 Appendix I

– Federal Agency Responsibilities for Maintaini ng Records About Individuals, OMB M

- 03

- 22

– OMB Guidance for Implementing the Privacy Provisions of the E

- Government Act of 2002, OMB M

- 06

- 15

– Safeguarding Personally Identifiable Information, OM:6

- 104

– Privacy Act of 1974 (Collection, Use and Protection of Personally Identifiable Information)5

ICRAS Tracking and OMB Number: (1472) 1845

- 0108 v2 Revised: 11 / 07 /2013 RIN Number: XXXX

- XXXX (if applicable) There is no assurance of confidentiality provided to institutions for the submission of this information. 11. Provide additional justification for an y questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. The justification should include the reasons wh y t he agency considers the questions necessary , the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and an y steps to be taken to obtain their consent. The De partment is not requesting any sensitive data. 12. Provide estimates of the hour burden of the collection of information. The statement should:

 Indicate the number of respondents by affected public ty

pe (federal government, individuals or households, pr ivate sector

– businesses or other for

- profit, private sector

– not
- for

- profit institutions, farms, state, local or tribal governments), frequency of response, annual hour burden, and an explanation of how the burden was estimated, including identification of burden t ype: recordkeeping, reporting or third party disclosure. All narrative should be included in item 12. Unless directed to do so, agencies should not conduct special survey s to obtain information on which to base hour burden estimates. Consulta tion with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widel y because of differences in activity , size, or complexity , show the range of estimated hour burden, and explain the reason s for the variance. Generall y, estimates should not include burden hours for customary and usual business practices.
 If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burden s in the ROCI S IC Burden Analy sis Table. (The table should at minimum include Respondent types, IC activity , Respondent and Responses, Hours/Response, and Total Hours)
 Provide estimates of annualized cost to respondents of the hour burdens for collections of information, identify ing and using appropriate wage rate categories. The cost of contracting out or pay ing outside parties for information collection activities should not be included here. Instead, this cost should be included in I tem 14.
Annual H our Burden for Respondents/Recordkeepers The burden hours calculated below include time for reviewing the changes in regulations; for determining the method and means to incorporate changes; and for developing or updating sy stems, forms and formats for ga thering the required information. The burden is all related to recordkeeping. Section 668.34 (a)

– Satisfactory academic progress policy6

ICRAS Tracking and OMB Number: (1472) 1845

- 0108 v2 Revised: 11 / 07 /2013 RIN Number: XXXX

- XXXX (if applicable)

We anticipate that it will take the 5,838 institutions 3 hours to review and update, as needed, their institutional policies, processes, and notifications. # of Respondents # of Responses Hrs/Response Burden Hours For
- profit institutions 2, 199 2, 199 X 3 hrs 6, 597 Private institutions 1,7 43 1,7 43 X 3 hrs 5, 229 Public institutions 1,89 6 1,89 6 X 3 hrs 5,6 88 TOTAL 5, 838 5, 838 17, 514 Previous totals 5,709 5,709 17,127 A net change from previous burden calculation +129 +129 +387 Section 668.34(c)

– Institutions that evaluate satisfactory academic pro gress at the end of each pay ment period. We estimate that 55% of eligible institutions review for SAP at the end of each pay ment period. 55% of the 21,026,924 non

- rejected FAFSA applications completed for the 2012

- 2013 award ye ar equals 11, 564,808 x 2 institutional reviews per year = 23,129,616 evaluations. Additionally , we estimate that 7% of these 11,564,808 FAFSA filers (809,537 x 2 reviews per ye ar = 1,619,074 evaluations) will not meet the SAP requirements at the institution and will require addi tional evaluation and consultation with the student by

the institution. # of Respondent s # of Responses Hrs/Response Burden Hours For
- profit institutions

– Evaluation of all students for SAP * 8 , 789 , 254 X .02 175 , 785 Private institut ions

– Evaluation of all students for SAP * 6 , 938 , 885 X .02 138 , 778 Public institutions

– Evaluation of all students for SAP * 7 , 401 , 477 X .02 148,030 Individuals not meeting SAP requirements 809 , 537 x 2= 1,619 , 074 X .17 275 , 243 For
- profit institutions

– Working with students not meeting SAP * 615 , 248 X .25 153 , 81 2 Private institutions

– Working with students not meeting SAP * 485 ,7 22 X .25 121, 43 1 Public institutions

– Working with students not making SAP * 518 , 104 X .25 129 , 526 TOTAL 8 09 , 537 26 , 367 , 764 1,142 , 6057

ICRAS Tracking and OMB Number: (1472) 1845

- 0108 v2 Revised: 11 / 07 /2013 RIN Number: XXXX

- XXXX (if applicable) Previous total 371,991 11,930,328 516,981 A net change from previous burden ca lculation + 4 37 , 546 +14,437 , 436 + 625 , 624

*

- To avoid double counting the number of respondents when developing these tables t he number of institutions is only included in the totals for section 668.34(a)

. Section 668.34(d)

– Institutions that evaluate satisfactory academic progress annually or less frequentl y than at the end of each pay ment period. We estimate that 45% of eligible institutions review for SAP annuall y. 45% of the 21,026,924 non

- rejected FAFSA applications com pleted for the 2012

- 2013 award ye ar equals 9,462,116 evaluations. Additionally , we estimate that 7% of these 9,462,116 FAFSA filers will not meet the SAP requirements at the institution and will require additional evaluation and consultation with the stud ent by the institution. # of Respondents # of Responses Hrs/Response Burden Hours For
- profit institutions

– Evaluation of all students for SAP * 3, 595 , 604 X .02 71 , 912 Private institutions

– Evaluation of all students for SAP * 2, 838 , 635 X .02 5 6 , 773 Public institutions

– Evaluation of all students for SAP * 3 , 027 , 877 X .02 60 , 558 Individuals not meeting SAP requirements 662 , 348 662 , 348 X .17 1 12 ,59 9 For
- profit institutions

– Working with students not meeting SAP * 2 5 1, 692 X .25 62 , 923 Private institutions

– Working with students not meeting SAP * 1 98 , 705 X .25 4 9 , 676 Public institutions

– Working with students not making SAP * 211 , 951 X .25 52 , 988 TOTAL 662,348 10 , 786 , 812 4 67 , 429 Previous total 603,327 9,732,636 412,748 A net change from previous burden calculation +59,021 +1,054,176 +54,681

*

- To avoid double counting the nu mber of respondents when developing these tables t he number of institutions is only included in the totals for section 668.34(a)

. Subpart E of Section 600

- Eligibility of Foreign Institutions Section 600.55

– Other criteria. # of Respondents # of Responses Hrs/Response # of Burden Hours8

ICRAS Tracking and OMB Number: (1472) 1845

- 0108 v2 Revised: 11 / 07 /2013 RIN Number: XXXX

- XXXX (if applicable) For
- profit institutions 4 4 X 2.5 10 Private institutions 5 5 X 2.5 13 Public institutions 1 8 1 8 X 2.5 45 TOTAL 27 27 68 Previous total 71 71 178 A net change from previous burden calculation

- 44

- 44

- 110
GRAND TOTAL 1,477 , 750 37 , 160 , 441 1, 627 , 616 Current B urden 984,598 21,672,244 977,03 2 A net change from previous burden calculation +493,152 +15 , 488 , 197 + 650 , 584
13. Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information. (Do not include the cost of any hour burden shown in I tems 12 and 14.)

 The cost estimate should be split into two components: (a) a total capital and start

- up cost component (annualized over its expected usef ul life); and (b) a total operation and maintenance and purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information. I nclude descriptions of methods use d to estimate major cost factors including s ys tem and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start
- up costs include, among other items, pr eparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and acquiring and maintaining record storage facilities.
 If cost estimates are expected to vary widel y, agencies should p resent ranges of cost burdens and explain the reasons for the variance. The cost of contracting out information collection services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60

- day

pre - OMB submission public comment process and use existing economic or regulatory

impact anal ys is associated with the rulemaking containing the information collection, as appropriate.
 Generally , estimates sho uld not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to9

ICRAS Tracking and OMB Number: (1472) 1845

- 0108 v2 Revised: 11 / 07 /2013 RIN Number: XXXX

- XXXX (if applicable) provide inform ation or keep records for the government or (4) as part of customary and usual business or private practices. Also, these estimates should not include the hourly costs (i.e., the monetization of the hours) captured above in Item 12 Total Annualized Capit al/Startup Cost : Total Annual Costs (O&M) :

____________________ Total Annualized Costs Requested : There is no new sy stem start
- up costs associated with these final regulations. 14. Provide estimates of annualized cost to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collecti on of information. Agencies also may aggregate cost estimates from I tems 12, 13, and 14 in a single table. There are no additional costs to the Federal government as a result of the final regulation. 15. Explain the reasons for an y program changes or adjustments. Generally, adjustments in burden result from re

- estimating burden and/or from economic phenomenon outside of an agency ’s control (e.g., correcting a burden estimate or an organic increase in the size of the reporting universe). Program changes result from a deliberate action that materiall y changes a collection of information and generally are result of new statute or an agency action (e.g., changing a form, revising regulations, redefining the respondent universe, etc.). Burden changes should be disaggregated by t ype of change (i.e., adjustment, program change due to new statute, and/or program change due to agency discretion), ty

pe of collection (new, revision, extension, reinstatement with change, reinstatement without change) and include tot als for changes in burden hours , responses and cost s (if applicable)

. Reasons for Changes to Burden Hour Estimated This collection extension is an adjustment in burden based on the increase of 650 , 584 burden hours . This increase is caused by an increase in the number of students for whom a determination of satisfactory academic progress must be made on an annual or semi

annual basis and a slight increase in the number of eligible institutions that must perform these determinations. 16. For collections o f information whose results will be published, outline plans for tabulation and publication. Address any complex analy

tical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collec tion of information, completion of report, publication dates, and other actions. The results of the collection of information will not be published.10

ICRAS Tracking and OMB Number: (1472) 1845

- 0108 v2 Revised: 11 / 07 /2013 RIN Number: XXXX

- XXXX (if applicable)
17. If seeking approval to not display the expiration date for OMB approval of the information collectio n, explain the reasons that display would be inappropriate. The Department is not seeking approval to not display an expiration date. ED will publish a Notice in the Federal Register announcing the OMB number and expiration date once approved. 18. Expla in each exception to the certification statement identified in the Certification of Paperwork Reduction Act. The Department is not requesting an y exceptions to the “Certification of Paperwork Reduction Act Submissions.”